Privacy Policy
Last Updated on: 30th January, 2023
This Privacy Policy governs the manner in which Herconomy Limited (“Herconomy,” “we,” “us,” and “our”) collects, uses, stores, and discloses information collected from our consumer users (“Users”, “you”). This policy describes what information we collect about you, how we collect and use the information you share with us, and with whom we share that information. You don’t have to share any information with us, but to use our services, we’ll need some information from you. This policy also contains information about when we share your personal information with third parties (such as our service providers and credit bureaus).
This Privacy Policy applies to use of our websites, applications, other online services and/or any related services, sales, marketing, promotional or events, and social media activities (collectively, our “Services”). For our Users, this Privacy Policy is part of our Terms of Use. This Privacy Policy applies to your use of (regardless of means of access) our Services. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a “Device”). This Privacy Policy also applies to offline interactions with Herconomy. By accessing or using our Services, you agree to this Privacy Policy.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepages of our website or mobile application or by sending you an email notification).
WHAT INFORMATION DO WE COLLECT?
You may be asked to provide your information including Personal Data anytime you contact us, and we shall use your Personal Data in accordance with this Privacy Policy.
Categories of Personal Data
We collect the Personal Data you provide to us when you apply for a Herconomy account or when you communicate with us about your Herconomy account. The types of Personal Data we may collect include your name, address, phone number, email address, date of birth, bank account information, BVN, username, password, and next of kin details.
Personal Data About Your Transactions With Us
As you use your Herconomy account to perform financial transactions, we collect Personal Data in connection with each transaction, including transaction time, amount and merchant details. We may also collect photos, memos or other information that you attach to your transactions
Personal Data From Third Parties
When you create a Herconomy account, we may collect information, including Personal Data about you from non-affiliated third-party service providers in order to verify your identity and for fraud prevention, including your prior addresses and names. We also work closely with third parties (including financial service providers, security agencies, etc) and will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Personal Data We Automatically Collect
We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you (“Analytics”). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.
Information that we automatically collect in connection with your access or use of our Services may include:
- • The Device's Internet Protocol ("IP") address
- • Identification numbers associated with your Devices
- • Device event information, such as crashes, system activity, and hardware settings
- • Date and time stamps of transactions
- • System configuration information
- • Other interactions with our Service
USE OF PERSONAL DATA
We may use your information, including Personal Data as follows:
- • Provide, maintain and improve our Services
- • Provide and deliver the products and services you request, process transactions and send you related information, including confirmations.
- • Verify your identity and prevent fraud.
- • Send you technical notices, updates, security alerts and support and administrative messages.
- • Respond to your comments, questions and requests and provide customer service.
- • Communicate with you about products, services, offers, promotions, rewards, and events offered by Herconomy and others, and provide news and information we think will be of interest to you.
- •Monitor and analyse trends, usage and activities in connection with our Services.
- • Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests.
- • Process and deliver contest or promotion entries and rewards.
- • Link or combine with information we get from others to help understand your needs and provide you with better service.
- • Carry out any other purpose for which the information was collected.
Lawful Basis For Processing Personal Data
- 1. To comply with our legal and regulatory obligations.
- 2. To perform a contract with you or to take steps at your request before entering into a contract.
- 3. To use your Personal Data as is necessary for our legitimate interests or the legitimate interests of others.
- 4. To protect your interest, the interest of another Data Subject or for the performance of a task carried out in the public interest or in exercise of official public mandate vested in us.
DISCLOSURE OF PERSONAL DATA
We may disclose any information we collect about current and former customers, including Personal Data, to affiliates and non-affiliated third parties as follows:
- • If you request or authorize it;
- • If the information is provided to help complete a transaction for you;
- • If the information is required to:
- • (a) comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas;
- • (b) enforce our Terms of Use or other agreements; or
- • (c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.);
- • If the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets);
- • If the information is provided to our third-party service providers to perform functions on our behalf (e.g., analysing data, providing marketing assistance, providing customer service, processing orders, etc.);
- • For our everyday business purposes;
- • For publication of our events and competitions on digital and print media.
- • We share your Personal Information with delivery companies and may publish your image where you have won a gift in our competitions, giveaways and promotions or as permitted by applicable law or otherwise described in this Privacy Policy.
We will usually not share your Personal Data with other third parties without your consent. Where we need to transfer your Personal Data to another country, we shall ensure that such country to which the data is being transferred shall have adequate data protection law. We will seek your consent where we need to send your data to a country without an adequate data protection law.
When you are no longer our User, we may continue to share your information as described in this Privacy Policy. We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.
We do not share your Personal Information with:
- • Other financial companies for joint marketing purposes;
- • Affiliated companies for their everyday business purposes; or
- • Any third parties so they can market to you
Your Rights
The Nigeria Data Protection Regulation (NDPR) gives you certain rights in respect of the Personal Data we hold about you. Below is a highlight of some of those rights. It is not a complete, exhaustive statement of your rights in respect of your Personal Data:
- 1. You have a right to consent to this Privacy Policy and to withdraw your consent at any time.
- 2. You have a right to a copy of the Personal Data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that data in the case of unfounded and excessive requests.
- 3. You have a right to freely transfer your data received from us to any other person.
- 4. You have the right to have the Personal Data we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose via support@herconomy.com
- 5. In some circumstances, you have the right to the deletion of the information that we hold about you.
- 6. You have a right to lodge a complaint about the handling of your personal information with the National Information Technology Development Agency (NITDA).
- 7. You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes.
SECURITY OF YOUR PERSONAL DATA
We have suitable security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorised way by a third party. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Information on our instructions. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration.
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Herconomy account and do not share them with others. If we receive instructions using your Herconomy account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your account or any other breach of security.
We reserve the right, in our sole discretion, to refuse to provide our Services, terminate accounts, and to remove or edit content.
RETAINED DATA
We shall retain your information for as long as your account is active or as needed to provide you with our services or comply with our legal and statutory obligations.
BREACH OF PERSONAL DATA
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data, we shall within 72 (Seventy-Two) hours of having knowledge of such breach report the details of the breach to NITDA.
Furthermore, where we ascertain that such breach is detrimental to your rights and freedoms in relation to your Personal Data, we shall within 7 (Seven) days of having knowledge of the occurrence of such breach take steps to inform you of the breach incident, the risk to your rights and freedoms resulting from such breach and any course of action to remedy said breach.
DELETION OR ERASURE OF PERSONAL DATA
We store data until it is no longer necessary to provide our services and Herconomy Products, or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. When you delete your account, we delete all the things you have posted, such as your photos, communication, status updates, and you won’t be able to recover that information later. Information that others have shared about you isn’t part of your account and won’t be deleted. If you don’t want to delete your account but want to temporarily stop using the Products, you can deactivate your account instead.
YOUR ACCEPTANCE OF THESE TERMS
By using this Application, you signify your acceptance of this policy and consent to the processing of your Personal Data. You may at any time after consenting to the processing of your Personal Data withdraw such consent. However, the withdrawal of consent shall not affect the lawfulness of the processing of your Personal Data prior to the withdrawal of consent. If you do not agree to this policy, please do not use our application and your continued use of the Herconomy application following the changes to this policy will be deemed your acceptance of those changes.
Contacting Us
If you have any questions about this Privacy Policy or your dealings with Herconomy App, please contact us online or by mail at:
Herconomy Limited
226, Bourdillon Rd,
Ikoyi, Lagos.
Email: info@herconomy.com
